December 19, 2024

Daniel Contreras
Chief Executive Officer
RAADR, INC.
1680 Michigan Avenue, Suite 700
Miami Beach FL, 33139

       Re: RAADR, INC.
           Offering Statement on Form 1-A
           Filed November 29, 2024
           File No. 024-12538
Dear Daniel Contreras:

       We have reviewed your offering statement and have the following
comments.

       Please respond to this letter by amending your offering statement and
providing the
requested information. If you do not believe a comment applies to your facts
and
circumstances or do not believe an amendment is appropriate, please tell us why
in your
response. After reviewing any amendment to your offering statement and the
information you
provide in response to this letter, we may have additional comments.

Offering Statement on Form 1-A
Business, page 22

1.     Please revise your discussion in this section and throughout to clarify
the principal
       market(s) for your products and services. Refer to Item 7(a)(1)(i) of
Form 1-A.
2.     You state on page 30 that your monthly lease for the Florida office is
$4,750 and for
       the Dublin office is $5,240. However, your disclosures on pages F-38 and
F-52
       indicate you have a monthly lease of $350. Please revise. In addition,
please explain
       why you believe the office space is adequate given your annual revenue
and
       operations. Refer to Item 8(a) of Form 1-A.
3.     We note your disclosure that Mexedia, Inc., a Florida Corporation, was
organized in
       2020. We further note that on January 1, 2023, Mexedia, Inc. acquired
all the shares
       of Phonetime, Inc. and Matchcom Telecommunications, Inc. Please provide
a more
       complete discussion regarding corporate history and operations of the
subsidiaries.
 December 19, 2024
Page 2
4.     We note your disclosure that Mexedia Limited is a wholly owned
subsidiary of
       Mexedia S.p.A S.B, an Italian company. Please revise the chart on page
24 to add
       Mexedia S.p.A S.B.
Directors, Executive Officers, Promoters and Control Persons, page 37

5.     We note that at least two of your officers and directors are also
officers and directors
       of Mexedia S.p.A. Please include an appropriately captioned risk factor
to discuss, if
       true, that your officers/directors serve in their position on a part-
time basis and/or
       otherwise clarify the number of hours they have agreed to dedicate to
the business
       affairs of your company. To the extent material, please also identify
and describe any
       potential conflicts of interest that exist, or may exist, as a result of
your executive
       officers' outside business relationships. Refer to Item 10 of Form 1-A.
6.     Please identify the current location(s) from where your officers,
partners, or managers
       primarily direct, control and coordinate your activities, and when these
individuals
       commenced their activities at this location(s).
General

7.     Please provide us with an analysis that supports your belief that your
principal place
       of business would be in the United States or Canada for purposes of
establishing your
       eligibility to conduct an offering under Regulation A. In this regard,
we note the
       change in control of your company and that Mexedia S.p.A. S.B. is a
publicly-held
       Italian corporation listed for trading on the Euronext Growth Paris
exchange, that
       Messrs. Taddeo and Gilcher are officers of Mexedia S.p.A, and that
Mexedia S.p.A
       identifies Mexedia Inc. as a 100% wholly owned subsidiary in their June
30, 2024
       financial statements. Refer to Securities Act Rule 251(b)(1). For
additional guidance,
       see Securities Act Rules Compliance and Disclosure Interpretation
182.03.
8.     In addition to qualifying a Regulation A offering with the Commission,
issuers in Tier
       1 offerings must register or qualify their offering in any state in
which they seek to
       offer or sell securities pursuant to Regulation A. Please provide a
written
       representation confirming that at least one state has advised the
company that it is
       prepared to qualify or register the offering.
 December 19, 2024
Page 3

         We will consider qualifying your offering statement at your request.
In connection
with your request, please confirm in writing that at least one state has
advised you that it is
prepared to qualify or register your offering. If a participant in your
offering is required to
clear its compensation arrangements with FINRA, please have FINRA advise us
that it has no
objections to the compensation arrangements prior to qualification.

        We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence
of action by the staff.

      Please contact Aliya Ishmukhamedova at 202-551-7519 or Matthew Derby at
202-
551-3334 with any other questions.



                                                            Sincerely,

                                                            Division of
Corporation Finance
                                                            Office of
Technology
cc:   Eric Newlan